Data Protection Policy
The Data Protection Officer for Sheppex Limited is Paul Coggins.
He can be contacted by writing to Sheppex Limited The Old Library, High Street, Wadhurst, East Sussex, TN5 6AP or emailed at firstname.lastname@example.org
Policy became operational on: 25th May 2018
Sheppex Ltd (Sheppex), is an Asset Finance business that provides access to Asset Finance facilities to Limited Companies and Corporate Bodies only, for the purchase of equipment for use in their businesses. Sheppex does not provide finance to individuals, partnerships or sole traders, where that business would be regulated by the Financial Conduct authority, (FCA).
In the course of its business Sheppex needs to gather and use certain information about companies and individuals that Sheppex organisation has a relationship with or may need to contact.
We must collect this information so that fair and informed lending decisions can be made by Sheppex employees, or any financial institutions that are trading partners of Sheppex.
This policy describes how this personal data will be collected, handled and stored to meet the company’s data protection standards and to comply with the law. Sheppex Ltd complies with the Data Protection Act 1998, the General Data Protection Regulation and the Data Protection Bill 2017-19 when enacted – these legislations will here on be referred to as ‘Data Protection Legislation’
Types of information we collect
Typical information that we collect would include but is not limited to: names and shareholders addresses, accounting information, passport or driving licences, bank details, and existing repayment histories.
Why do we collect it?
This information is collected to help make fair lending decisions, but also to comply with the FCA legislation and Bribery and Corruption Law relating to how we trade and conduct our dealings. Is also requires us to be clear who we are dealing with when identifying our customers. This legislation requires us to be vigilant in our trading to avoid fraudulent or corrupt dealings with any entity, particularly those that may miss-represent their identity.
Why this policy exists
This data protection policy ensures Sheppex Ltd complies with data protection legislation and follows good practice. It protects the rights of staff, customers and trading partners. It shows that Sheppex Ltd is open about how it stores and processes individuals’ data and protects itself from the risks of a data breach.
Data protection law
The Data Protection Legislation, describes how organisations — including Sheppex Ltd must collect, access, and store personal information. These rules apply regardless of whether data is stored electronically, on paper or on other materials. To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. The legislation is underpinned by eight important principles. These say that personal data must:
- Be processed fairly and lawfully
- Be specific to its purpose
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with the rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), unless that country or territory also ensures an adequate level of protection
People, risks and responsibilities
This policy applies to:
- All directors and employees of Sheppex.
- Any contractors, suppliers and other people working on behalf of Sheppex Ltd
- It applies to all data that the company holds relating to identifiable living individuals, even if that information technically falls outside of the Data Protection Act 1998.
- “Identifiable living individual” means a living individual who can be identified, directly or indirectly, in particular by reference to:
- an identifier such as a name, an identification number, location data or an online identifier, or
- one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
Data protection risks
This policy helps to protect Sheppex Ltd from data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Everyone who works for or with Sheppex Ltd has some responsibility for ensuring data is collected, stored and handled appropriately. Each person that handles personal data must ensure that it is handled and processed in line with this policy and data protection principles.
All employees have an obligation to keep up to date with Data Protection Legislation that relates to them. The Directors have further obligations:
- Keeping the board updated about data protection responsibilities, risks and issues.
- Reviewing all data protection procedures and related policies, in line with an agreed schedule.
- Ensuring data be obtained only for specific, lawful purposes
- Arranging data protection training and advice for the people covered by this policy.
- Handling data protection questions from staff and anyone else covered by this policy.
- Dealing with requests from individuals to see the data Sheppex holds about them (also called ‘subject access requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.
- IT.ally Limited is contracted to Sheppex Limited as its maintenance and support partner for the companies IT infrastructure and is responsible for:
- Ensuring all systems, services and equipment used for storing data meet acceptable security standards.
- Performing regular checks and scans to ensure security hardware and software is functioning properly.
- Evaluating any third-party services the company is considering using to store or process data. For instance, cloud computing services.
General staff guidelines
- The only people able to access data covered by this policy should be those who need it for their work.
- Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers.
- Employees should keep all data secure, by taking sensible precautions and following the guidelines below.
- In particular, strong passwords must be used and they should never be shared.
- Personal data should not be disclosed to unauthorised people, either within the company or externally.
- Data should be regularly reviewed and updated if it is found to be out of date. If no longer required, it should be deleted and disposed of.
- Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the IT contractor or data protection officer. When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:
- Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer. Files should be stored in a locked drawer or filing cabinet.
- Data printouts should be shredded and disposed of securely when no longer required.
- When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
- Data should be protected by strong passwords that are changed regularly and never shared between employees.
- If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used.
- Data should only be stored on designated drives and servers, and should only be uploaded to an approved cloud computing services.
- Servers containing personal data should be sited in a secure location, away from general office space.
- Data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures.
- Data should not be saved directly to laptops or other mobile devices like tablets or smart phones.
- All servers and computers containing data should be protected by approved security software and a firewall.
Personal data is of no value to Sheppex unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft:
- When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
- Personal data should not be shared informally unless directly from the Data Subject. In particular, where possible it should not be sent by email, as this form of communication is not secure.
- If possible, personal data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
- Personal data should never be transferred outside of the European Economic Area.
- Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
The law requires Sheppex to take reasonable steps to ensure data is kept accurate and up to date. The more important it is that the personal data is accurate, the greater the effort Sheppex should put into ensuring its accuracy. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
- Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets.
- Staff should take opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
- Sheppex will make it easy for data subjects to update the information the company holds about them. For instance, via the company website.
- Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
- It is the director’s responsibility to ensure marketing databases are checked against industry suppression files every 12 months.
Subject access requests
All individuals who are the subject of personal data held by Sheppex are entitled to:
- Ask what information the company holds about them and why.
- Ask how to gain access to it.
- Be informed how to keep it up to date.
- Be informed how the company is meeting its data protection obligations.
- Complete and free of charge deletion within 14 days
If individual contacts the company requesting this information, this is called a subject access request. Subject access requests from individuals should be made by email, addressed to the data controller at: email@example.com The data controller can supply a standard request form, although individuals do not have to use this. The data controller will aim to provide the relevant data within 14 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.
Disclosing data for other reasons
In certain circumstances, the Data Protection Act allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Sheppex will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.
Sheppex aims to ensure that individuals are aware that their data is being processed, and that they understand:
- How the data is being used
- How to exercise their rights
To these ends, the company has a privacy statement, setting out how data relating to individuals is used by the company.
Any queries regarding this policy should be made in the first instance to the data protection officer.